For most of the past century, wealthy families leaving high-tax jurisdictions went to one of three places: Switzerland, Monaco, or, in one of history’s better ironies, London, whose non-dom regime sheltered foreign fortunes for over two centuries.
That map has now been redrawn. Switzerland has grown ambivalent about foreign wealth, Monaco has no room left, and Britain abolished its non-dom regime in April 2025, turning the country into a departure lounge for its own wealthy.
Much of that departing wealth is landing in Italy, which in under a decade has assembled the most complete relocation offer in Europe: a capped flat tax on foreign income, an investor visa with the continent’s lowest serious entry point, and a government that has kept its promises to every arrival. Over the past eighteen months, a procession of London’s most prominent bankers, industrialists, and billionaires has quietly rerouted to Milan.
The data tell the same story. Henley & Partners estimates Italy attracted 3,600 migrating millionaires in 2025, the largest net inflow in Europe and third worldwide behind only the UAE and the United States; Switzerland managed 3,000, Portugal 1,400, Greece 1,200. And this in the most crowded year wealth migration has ever recorded, with 142,000 millionaires relocating globally and 165,000 expected in 2026. Italy did not ride that wave. It caught more of it than any country in Europe.
A Tax That Keeps Getting More Expensive, and More Popular
The engine is the flat-tax regime for new residents under Article 24-bis of Italy’s tax code. Anyone who becomes an Italian tax resident after spending at least nine of the previous ten years abroad can replace ordinary taxation on all foreign-source income with a single annual payment, for up to 15 years. Whether that income is €1 million or €50 million, the bill is the same.
The price has climbed steeply: €100,000 at launch in 2017, €200,000 from August 2024, and €300,000 since the 2026 Budget Law took effect on January 1, with the family-member charge doubling to €50,000.
Whether demand survives the latest hike is not yet measurable: tax declaration data lag two years, and the government’s own projections assume the €300,000 rate will roughly halve new entrants. Early indicators point the other way. Henley & Partners reports interest remained resilient after January’s increase, concentrating among ultra-high-net-worth families for whom €300,000 still undercuts the 45 to 50 percent marginal rates they would face elsewhere in Europe, and the 2024 doubling produced no visible slowdown in relocations.
Official data tell the same story. Italy’s Court of Auditors counted nearly 1,500 participants in 2023 alone, a 31.6 percent year-on-year jump, and recorded €315 million in revenue between 2020 and 2023; total sign-ups since 2017 are estimated at approximately 4,000, including family members.
Two design choices explain the resilience, according to Christopher Downing of Vignale Capital, who advises relocating families on the regime.
“Rome has honored grandfathering at every reform,” Downing says. “A 2017 entrant still pays €100,000 while his 2026 neighbor pays triple, and that matters more to our clients than the headline number.”
The government also dropped the proposal to attach a mandatory investment requirement to the regime. Predictability, it turns out, sells better than cheapness.
The London Dividend
Britain handed Italy its largest source market. When the UK abolished its non-dom regime in April 2025 and moved to worldwide taxation, there was a net outflow of 16,500 millionaires from the country that year, the largest ever recorded and more than double China’s figure.
Many of the most prominent leavers chose Milan. Goldman Sachs vice chairman Richard Gnodde relocated there after nearly four decades in London, joining Aston Villa owner Nassef Sawiris, consumer-goods veterans Elio Leoni-Sceti and Bart Becht, and, this month, Iceland’s first billionaire, Thor Björgólfsson. Björgólfsson has since urged Britain to adopt an Italian-style capped tax, which is perhaps the sincerest form of flattery.
Buyer data confirms the wave. Lionard Luxury Real Estate, one of Italy’s leading luxury property brokerage firm, recorded a 260 percent surge in UK purchase inquiries for Milan between 2023 and 2025, against 42 percent growth in the Italian market overall.
The Residency Toolkit
Tax residence still requires a right to reside, and for non-EU nationals, Italy’s Investor Visa has become the natural companion to the flat tax.
Thresholds start at €250,000 in an innovative startup, with alternatives of €500,000 in an Italian company, €2 million in government bonds, or a €1 million donation, and the program imposes no minimum stay while requiring the investment only after approval.
Applications reached 209 by December 2025, a 62.6 percent compound annual growth rate since 2018, with decisions still issued within 30 days.
Italy’s timing is fortunate. Spain closed its golden visa in April 2025, Portugal’s fund route now starts at €500,000, and Greece’s prime zones demand €800,000, leaving Italy with the lowest serious entry point in Western Europe.
The fiscal menu extends beyond the ultra-rich. Foreign pensioners settling in southern towns pay a 7 percent flat rate on all foreign income for ten years, a regime expanded in April 2026 to municipalities of up to 30,000 residents, unlocking 74 new towns. Working relocators can claim the impatriati exemption of 50 percent on Italian employment income up to €600,000, rising to 70 percent in the south.
Reading the Signal
A government that raises the price of admission twice in two years, and watches applications climb anyway, has found genuine product-market fit.
For families weighing an exit from high-tax jurisdictions, the calculation now favors acting before the next recalibration rather than after it.
Structuring the move correctly matters as much as making it: residence timing, the advance tax ruling, and the interaction between the flat tax and the Investor Visa all reward early planning.
To assess whether Italy fits your circumstances, contact Vignale Capital for a confidential consultation; the firm advises high-net-worth families on Italian residence, investment structuring, and flat-tax elections from application through relocation.
